Amendments to the Polish Pillar Two (BEPS 2.0.) Act. What taxpayers need to know?
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On March 25, the AmCham Tax & Financial Services Committee hosted Michał Koper, dr Filip Majdowski, and Arkadiusz Myszkowski from EY Polska for a discussion on the amendments to the Polish Pillar Two (BEPS 2.0) Act.
The meeting provided a comprehensive overview of recent legal changes and the evolution of the system in recent years. We explored broader policy considerations, particularly within the tax sector, and discussed the growing importance of domestic obligations related to calculating and paying minimum tax levels. A comparative analysis of different jurisdictions highlighted varying approaches, with some systems being more centralized, while others require closer supervision.
An important part of the discussion was a general “stocktaking” of the current landscape, including how the rules are being implemented and what changes are anticipated from 2026. It was noted that, although the new framework may not directly increase revenues, it could have a significant impact on overall taxation levels. The group also examined, at a high level, the treatment of incentives and reliefs, pointing to a gradual shift toward greater flexibility.
The discussion further covered compliance requirements for the coming years, the critical role of accounting standards in tax calculations, and the need to align local regulations with international guidelines. We also addressed upcoming legislative developments, including limitations, transitional provisions, and the treatment of certain assets established prior to earlier reforms.
Finally, practical aspects were considered, such as reporting obligations and the possibility of applying certain options retrospectively. This would, however, require careful coordination between headquarters and local entities, as well as the necessary internal approvals.
Thank you to our speakers, as well as to Adam Soska and Tomasz Lenart, Co-Chairs of the AmCham Tax & Financial Services Committee, for selecting this important topic and moderating the discussion.
SPEAKERS
Michal Koper
Filip Majdowski
Arkadiusz Myszkowski